I will be following the $GNS VERY closely. Congrats on this filling @rogerhamilton. My Board was mostly spineless and got rid of me right before the 1st Economist/Expert internal spoofing report landed, then sat on the reports (two independent Economist reports... more on that soon) Some initial $GNS vs Market Makers thoughts, which are also valid for our MMAT/MMTLP trustee-led case: I searched for official sources regarding the scope and use of the “bona fide market making” (BFMM) exemption under Regulation SHO and found several relevant references. When you read up on the Market-Maker BFMM exemptions (which Citadel and Virtu like to hide behind... more on BFMM next) and compare Market Making in USA vs. other countries... you discover some spectacular and scary facts. To keep things simple, I will use an analogy, so bare with me please. Market makers are like #lifeguards: They have been given special rights only to SAVE swimmers, not to play water games. 🛟Real lifeguard duties (parallel to BFMM exemption): 1. Watch the pool at all times → continuous quoting 2. Respond to people on both sides of the pool → two-sided liquidity 3. Stay neutral, not pick favourites → non-directional, low-risk exposure 4. Intervene when a swimmer struggles → temporary imbalances 5. Act only for safety → customer-driven activity 6. Never-EVER create waves or splash people → no artificial volatility (NBBO manipulation) ❌ What Citadel/Virtu effectively argue: “Since lifeguards can grab swimmers, we’re allowed to pull swimmers underwater, dunk them for fun, and then claim we’re ‘fulfilling our role... if they drown, they drown... we are exempt!" 🤡 Hell No. The exemption exists to SAVE people, not to drown them for PROFIT. That's the difference between REAL market making and spoofing + directional short campaigns. NOW, if you want REAL market making, you look to: Japan, EU, UK, Singapore, Korea, and Switzerland. These are markets where a “market maker” is NOT just a label.... it is a CONTRACT, with explicit duties, quoting rules, risk caps, and exchange supervision. 🇯🇵 Japan (Tokyo Stock Exchange): One of the strictest in the world. Japan has true market-making schemes: Enforced requirements: -Continuous two-sided quoting -Max spreads -Minimum quote sizes -Maximum quote fade times -Penalties for failing obligations -Suspension and removal for violating quoting requirements Why it’s real: Market makers must demonstrate they are actually stabilizing markets, not internalizing and hiding orders. 🇪🇺 European Union (all MiFID II countries). Under MiFID II, the EU has statutory, enforceable market making obligations. Required: -Continuous quoting -Maximum spreads -Minimum presence time -Stress-period obligations -Ability to prove “liquidity provision” is not directional speculation Bonus: EU regulators track if “market makers” quote BOTH sides. If they don’t, the designation is REMOVED. 🇬🇧 United Kingdom (post-MiFID equivalent rules) London Stock Exchange (LSE) has: -“Registered Market Maker” contracts -Minimum quote sizes & % of trading day coverage -Obligations even during volatility auctions -Monitoring via LSE surveillance units Real consequence: Fail obligations → immediate sanctions or termination. 🇸🇬 Singapore (SGX), is very disciplined. SGX is known for proper, contractual market-making: -Tighter spread caps -Minimum size -Time-in-market % -No one-sided quoting allowed -Public disclosure of market makers per instrument SGX publishes compliance reports, a sign of transparency rarely seen in the U.S. 🇰🇷 South Korea (KRX) -KRX imposes strict, formula-based obligations: -Continuous quotes -Maximum spreads -Time obligations -Penalties for breaches -Fines and removal for directional manipulation KRX also BANS payment for order flow, a major U.S. conflict of interest. 🇦🇺 Australia (ASX). ASX has regulated market-making for ETFs, derivatives, and select equities: -Tight quote obligations -No “phantom liquidity” (immediate cancels) -Surveillance for odd-lot spoofing -Penalties for failing to maintain two-sided markets 🇨🇭 Switzerland (SIX Exchange). Switzerland’s system is exceptionally clean: -Contractual obligations -Real risk-taking -Exchanges match liquidity providers with issuers -No internalization of retail order flow -No PFOF -No wholesale HFT dominance Many consider SIX the “purest” equity market structure left. 🇭🇰 Hong Kong Exchange (HKEX). Very strict: -No PFOF -No wholesaler internalization -MM must be present 70–90%+ of trading hours -Tight spreads enforced -Removal for statistical deviations 🌍 Countries With “Pseudo” Market Making (Not real) 🇺🇸 United States. This is where “market making” is marketed, not enforced. 🇨🇦 Canada is not too far behind either😢 #Wholesalers like Citadel/Virtu: -No continuous quoting obligations -No maximum spreads -No minimum quote durations -No duty to remain two-sided -Can internalize 40–60% of retail flow -Can operate dark -Face almost no penalties for abandoning markets -Use Reg SHO exemptions designed for real market makers Conclusion: The U.S. has ZERO real, contractual market makers in equities. Citadel/Virtu are WHOLESALERS with exemptions, nothing more. 🛟 Real Lifeguard’s job: Jump in only when someone is drowning (liquidity imbalance). ❌ Citadel/Virtu: -Doing laps all day -Shoving swimmers underwater -Taking people’s towels and valuables while they’re distracted -Claiming immunity because “I’m a lifeguard” If you want “fake market making” directional shorting + internalization + exemptions, you get: Citadel & Virtu. #Bitcoin at least has neutral settlement: 1. No one controls it. 2. No one internalizes your flows. 3. No one sells your order flow to a high-speed predator. Bitcoin is a 🏖️beach with no lifeguards at all, but at least it doesn’t lie to you about who controls the water 🌊 Ironically, Bitcoin has MORE integrity in its settlement layer than the U.S. stock market. Crypto exchanges... that's a different story (for now). HOPE😇: I believe that the U.S. WILL fix its market structure... but only because it will eventually have no choice. Bigger forces are converging: 1. Bitcoin proves settlement can be transparent 2. EU & Asia prove market makers can be obligated 3. Retail now understands the game 4. Congress is finally poking holes in the DTCC shell 5. Lawsuits like $GNS & others (expected) expose the cracks Very soon, Artificial Intelligence will make monitoring and forensic analysis both easy and FUN... and I dream of the day that Issuers and Retail (not just the regulators) have that kind of power, and I will support making this happen.